COS Response to Proposed OMB Rule on Federal Financial Assistance

This record contains the Center for Open Science's (COS) public comment in response to the White House Office of Management and Budget's (OMB) proposed rule on Regulations for Federal Financial Assistance, submitted to docket OMB-2026-0034. The proposed rule represents a significant change to the Uniform Guidance governing federal financial assistance (2 CFR Part 200), codifying several concerning elements of the Executive Orders on Improving Oversight of Federal Grantmaking and Restoring Gold Standard Science. The record comprises two documents: Public comment — the formal comment submitted through the text box in regulations.gov, summarizing COS's position within the docket's 5,000-character limit. Detailed companion analysis — an additional document submitted to OMB as a PDF providing detailed, provision-by-provision analysis with supporting citations. COS's comment opposes several proposed provisions on the grounds that they would compromise the openness, integrity, and trustworthiness of federally funded research. It is organized around two themes, with a closing observation drawn from OMB's own Regulatory Impact Analysis: Theme 1 notes that the rule compromises the independence and integrity of federally funded research by inserting senior political officials into the review and decision-making process across the grant lifecycle. The comment addresses proposed revisions that impact program design (§200.202), merit review and political pre-issuance review of awards (§200.205), and discretionary termination of active awards (§200.340). COS argues that these provisions subordinate independent expert evaluation to shifting political priorities. Theme 2 notes that the rule limits researchers' ability to freely communicate and disseminate their work, placing new restrictions on conference participation (§200.432), communication with the public and policymakers (§200.450), and the publication costs that enable open access to research findings (§200.461). The comment closes by noting that the rule's provisions are in tension with OMB's own stated objective of reducing recipient burden, citing the Regulatory Impact Analysis's acknowledgment that OMB "was unable to quantify the expected costs of the rule."